Missed Contribution Confusion

[khn]

We have a situation where 2 participants have investment elections on file, but due to an administrative error deferrals were not taken from their check for 3 months.

My interpretation from EPCRS is that the actual returns should be calculated, and if those happen to be negative than go with the DOL calculation because you have to at minimum make the participant whole. In the event there's no investment election on file, then a weighted average method could be used. The Highest Performing Fund calculation can also be used if it's easier to calculate, but this could prove to be much more expensive.

Am I correct?? I am getting confused between this and the missed opportunity deferrals.